The Arkansas Court of Appeals ruled on November 4, 2026, that Westside Consolidated School District No. 5 did not violate state law when it chose not to renew Ulanda Digby-Branch's contract as assistant principal. The court found that the school district substantially complied with the Arkansas Teacher Fair Dismissal Act (TFDA) and its personnel policies. This decision affects educators in Arkansas, particularly those facing contract nonrenewals.

The case, Ulanda Digby-Branch v. Westside Consolidated School District No. 5, is significant as it clarifies the application of the TFDA regarding contract nonrenewals and the school district's reduction-in-force (RIF) policies. The ruling highlights the importance of compliance with established personnel policies in educational institutions.

Background

Ulanda Digby-Branch began her career with Westside Consolidated School District in 2015, initially serving as the high school assistant principal before moving to the middle school in 2016. By the 2019-2020 school year, she was notified by Superintendent Scott Gauntt that her contract would not be renewed. This decision was based on several factors, including the district's financial difficulties and the non-required status of her position according to Arkansas educational standards.

Digby-Branch contested the decision, arguing that the district did not follow its RIF policy, which should have been invoked due to her nonrenewal. She requested a hearing, which took place on April 23, 2020. During the hearing, Gauntt explained the district's budget shortfall and the results of a staffing-efficiency review that indicated her position was surplus. The school board unanimously voted against renewing her contract.

Following the board's decision, Digby-Branch appealed to the Craighead County Circuit Court. The circuit court initially ruled in favor of the district, but the Arkansas Court of Appeals reversed this decision on a previous occasion, stating that material facts remained regarding the application of the RIF policy. The case was remanded back to the circuit court for further consideration.

The Ruling

On remand, the circuit court held a bench trial on April 24, 2025. The court found that the district had substantially complied with the TFDA and its personnel policies when deciding not to renew Digby-Branch's contract. The court noted that Gauntt had referred to the RIF policy as a guideline for determining seniority but did not invoke it as the basis for the nonrenewal.

The court ruled, "The evidence here was that a staffing-efficiency review identified one surplus licensed position in the District: the middle school assistant principal."

The circuit court concluded that the elimination of Digby-Branch's position did not trigger the RIF policy because the position was not required by state standards and the district could not afford to retain it. The court also found no evidence that the reasons for nonrenewal were untrue or that Gauntt's recommendation was based on personal animus.

In its opinion, the court stated, "On this record, we are not left with a firm conviction that the circuit court erred in finding that the District substantially complied with the TFDA and its applicable personnel policies." This ruling affirmed the circuit court's decision and upheld the actions of the Westside Consolidated School District.

Impact

This ruling has significant implications for school districts and educators in Arkansas. It clarifies that a school district does not need to invoke its RIF policy if it can demonstrate that a position is not required and that budgetary constraints necessitate its elimination. This decision emphasizes the importance of following established personnel policies while also allowing for flexibility in managing school staffing based on financial realities.

Additionally, the court's ruling reinforces the idea that school administrators can make decisions based on staffing reviews and budget considerations without necessarily triggering the more complex RIF procedures, as long as they substantiate their decisions with valid reasons. This could potentially streamline the process for school districts facing similar financial challenges in the future.

What's Next

It is unclear if Digby-Branch will appeal this decision further. The court's ruling is final unless challenged in a higher court. There are no related cases pending at this time. The outcome of this case may influence future disputes regarding contract nonrenewals in Arkansas schools, especially in the context of budget constraints and personnel policies.